Despite supposedly harmonized environmental legislation in the EU, more and more diverging national requirements have been identified in recent years. This comes with great challenges for manufacturers and distributors of electrical appliances, for example with respect to labelling and information obligations.

Since the beginning of 2021, France has been requiring an assessment and labeling of certain electrical and electronic devices with regard to their reparability (“indice de réparabilité”). Now, Spain is taking corresponding steps towards the introduction of an “índice de reparabilidad”.

The Spanish Prime Minister’s Office “La Moncloa” has communicated that preparation of a respective regulation has already been completed. The communication suggests, that the Spanish repair label will, just like France, provide an index ranging from 0-10, which shall depict the reparability, but also various other criteria such as the availability of software updates. Compliance with individual criteria is to be verified by the manufacturers by self-assessments similar to what is already provided for in the French regulation.

The Spanish Ministry of Consumer Affairs is currently preparing the draft law, which is to include information campaigns and detailed catalogs of criteria in addition to labeling specifications. Whether and to what extent the Spanish labeling requirement will correspond to the French specifications in the end remains to be seen.

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